A company (GT Ltd) was incorporated in May 2011, with an initial shareholder (AG) owning its entire allotted share capital of 100 shares of £1 each. In July 2011, AG resolved to subdivide the company’s share capital into 1,000 shares of 10p each.
The company’s annual return to 13 May 2012 filed at Companies House included a list of shareholders, showing that AG held 645 ordinary shares, the appellant held 225 ordinary shares (22.5%), and the remaining 130 shares were divided between six other individuals.
One month later, an annual return to 14 May 2012 (i.e. one day after the date shown on the previous return) was filed at Companies House, showing AG as owning 1,000 ordinary shares, and the appellant as holding no ordinary shares.
Subsequently, the company entered administration. The appellant claimed a loss on the deemed disposal of his shares in GT Ltd. However, following an enquiry
